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20 007 Tax Accounting Unravelling Mystery Income Taxes Second Revised Edition Final Print
20 007 Tax Accounting Unravelling Mystery Income Taxes Second Revised Edition Final Print
20 007 Tax Accounting Unravelling Mystery Income Taxes Second Revised Edition Final Print
The impact of COVID-19 on the results of companies’ operations is discussed, consideration being given to the
challenges the current market volatility may present for companies closing their financial statements. Other issues
addressed include deferred tax assets recognition, impairment, increased need of cash by a group and distribution
of dividends, and government grants and reliefs. Finally, a case study gives the reader a better understanding on
how to arrive at the correct tax figures and disclosure notes, and in doing so truly unravels the mystery of how the
reported income taxes can be explained.
Benefitting from the extensive insight and experience of the authors, the book will serve as a valuable reference
tool to assist tax accountants, (tax) auditors, tax authorities, legislators, tax practitioners, and tax managers and
directors in their daily practice, as well as a guideline for newcomers to the tax accounting environment.
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It has been only five years, but so many changes have taken place since
then. On top of compressed close cycles, as well as new reporting consid-
erations and standards, companies are facing challenges due to increased
regulatory scrutiny over income tax disclosures and account balances. In
today’s increasingly complex business and tax environment, the demands
for transparency have never been stronger. An ever-wider variety of stake-
holders show an interest in how tax affairs are being managed and how
much companies pay. Public deficits due to COVID-19 support packages
will only trigger more public attention to tax affairs. Further, the guidance
with respect to tax reporting increased at EU, OECD and jurisdictional
level. In addition, guidance has been issued on good tax governance, tax
risk management, and tax reporting and compliance by the UN Principles
for Responsible Investment (PRI). Most recently, increased attention by
the Global Reporting Initiative for taxes resulted in the newly developed
GRI 207: Tax 2019 – the first public global standard for comprehensive tax
disclosures.
The basis of this book is still the ten-step methodology for accounting for
income taxes that can be applied in every jurisdiction around the globe.
The chapters of the book, written by experts in the field, aim to apply and
explain these ten steps.
This updated publication covers the latest IFRS and IFRIC guidance for
income taxes.
v
Foreword
Tax Treatments; (iii) tax accounting and tax risk management checklists;
(iv) the impact of technology and new transparency initiatives; and (v) the
impact of COVID-19 on companies.
vi
Table of Contents
Foreword v
1.1. Introduction 1
vii
Table of Contents
2.1. Introduction 55
viii
Table of Contents
3.1. Introduction 75
4.1. Introduction 91
ix
Table of Contents
5.6. Tax base as the basis for calculating deferred tax 127
5.6.1. Tax base of an asset 128
5.6.2. Tax base of a liability 130
5.6.3. Tax base of revenue received in advance 132
5.6.4. Uncertainty in determining the tax base 133
x
Table of Contents
xi
Table of Contents
6.3. Deferred tax assets on unused tax losses and credits 168
6.3.1. Background 168
6.3.2. The threshold: “Probable” 169
6.3.3. History of recent losses 176
6.3.4. Convincing other evidence 178
6.3.5. Specific tax regimes 180
xii
Table of Contents
xiii
Table of Contents
xiv
Table of Contents
xv
Table of Contents
xvi
Table of Contents
Background 411
xvii
Chapter 1
1.1. Introduction
To ensure that the theory discussed in the 10-step methodology directly con-
nects with actual practice, examples are offered that come directly from the
practical experience of the various authors. The first and foremost objective
is to explain clearly to the reader a methodology regarding how to structure
the accounting for income1 taxes and to acquaint the reader with the theory
and background of the various dogmas in the income tax standard.
* Partner, Netherlands TRS practice & EMEA Tax Accounting Services leader, PwC.
1. This is irrespective of whether one is a preparer or an auditor of (the income tax
paragraph in) financial statements.
1
Chapter 1 - Introduction to Tax Accounting
In addition, the place that accounting for income taxes and the respec-
tive standard has in the current environment is depicted and explained.
The world has changed rapidly, and financial accounting – especially tax
accounting – attracts the attention of a variety of stakeholders compared to
the late 1990s. At the end of 2014, when the first edition of this publication
was published, tax transparency became a serious topic. It is fair to say that
the call for transparency is now louder than ever. An ever-wider variety of
stakeholders show an interest in how tax affairs are being managed and how
much companies pay. Public deficits due to COVID-19 support packages
will only trigger more public attention in tax affairs.
This chapter explains the importance of accounting for income taxes. Key
definitions will be presented, followed by an explanation of the 10-step plan
and thus the core structure of the publication. Next, various initiatives are
outlined that promote increased transparency and fairness in the payment of
income taxes. Finally, the discussion shifts to the IASB as an organization,
as well as the place that the International Financial Reporting Standards
have in the world of financial accounting and how the Standards came to
be in this position.
Many people will ask what is the relevance or importance of accounting for
income taxes. The quick answer is that income taxes generally are one of
the largest line items on a company’s income statement. The more elaborate
answer is that there are differences between the rules2 that govern finan-
cial accounting and the rules that govern tax. Thus, the question concerns
whether those differences are permanent or temporary in nature and whether
these are reflected correctly in the financial statements. This is generally
seen as a complex exercise that needs to be performed by tax accounting
professionals.
2
Primary tax accounting terminology
The complexity increases and, thus, the importance, if one looks at account-
ing for income taxes in the context of multinational companies. The main
reason is that tax law is applicable on a jurisdictional basis and differs from
one jurisdiction to the next around the world, while the rules that govern
financial accounting provide for a single set of reporting standards that are
globally applicable. This combined with the fact that income and other taxes
impact multiple areas of business, and are embedded through many line
items in financial statements, makes taxes and – therefore the accounting
for income taxes – a key risk area for many companies.
Tax accountants know and understand tax complexities such as transfer pri-
cing, cross-border issues, hybrid loans and transparent entities. Furthermore,
they know and understand the respective differences – either permanent or
temporary in nature – that can arise between the principles used for financial
reporting and those established by tax law. As can be seen in financial state-
ments – even in single-entity financial statements – the reported tax expense
seldom reflects the profit before tax multiplied by the statutory tax rate. Tax
accountants focus on those differences. Basically, tax accounting is the fine
art of connecting and reflecting the two worlds of financial accounting and
tax in the financial statements.
3
Chapter 1 - Introduction to Tax Accounting
A firm grasp of the most relevant (tax) accounting terms5 is also essential to
understanding the tax provision process. These terms are considered below,
following the structure of the financial statements. According to IAS 1,6 a
complete set of financial statements consists of the following elements:
Deferred tax assets and deferred tax liabilities reflect the future tax
consequences of temporary differences between the carrying values (or
book basis) of assets and liabilities recognized on the balance sheet and
their respective tax basis.8 A deferred tax asset represents the amount
of taxes expected to be received or recovered in the future as a result of
(i) deductible temporary differences and (ii) the carry-forward of un-
used tax losses and/or tax credits. A deferred tax liability reflects the
amount of income tax expected to be paid/incurred in the future as a
result of the reversal of taxable temporary differences. All deferred tax
balances are classified as non-current.
5. IFRS do not contain a single list of definitions. Rather, all individual standards
contain their own relevant definitions. Those listed here are predominantly found in IAS
1 and IAS 12.
6. IAS 1, para. 10.
7. IAS 12, para. 5.
8. The tax basis of an asset or liability is the amount attributed to that asset or liability
for tax purposes.
9. IAS 12, para. 5.
4
Primary tax accounting terminology
– A statement of cash flows for the period. The statement of cash flows
provides information about the changes in cash and cash equivalents
during the reporting period, and requires that cash flows during the
period be classified as pertaining to (i) operating, (ii) investing or (iii)
financing activities. Income taxes are generally classified as pertaining
to operating activities. Additionally, cash outflows for income tax pay-
ments made to tax authorities during the reporting period must be sep-
arately disclosed in the statement of cash flows or in the notes to the
financial statements. In principle, cash flows arising from taxes on in-
come are to be classified as cash flows from operating activities.11
5
Chapter 1 - Introduction to Tax Accounting
14. Or US GAAP.
6
How are income taxes accounted for?
The starting point for all tax (accounting) calculations is the “commercial”
profit before tax. Therefore, the first step is to identify whether tax law
demands or creates a difference in tax treatment as compared to how a
certain transaction was treated and recorded under the applied accounting
standard. Such differences are either permanent or temporary in nature.
15. For a detailed outline and discussion of this first step, see ch. 3.
16. This means that a proper understanding of how and where items are reported for
GAAP and IFRS purposes will aid in the effective application of IFRS and/or US GAAP.
17. Generally, IFRS or US GAAP.
18. Which is hardly the case.
19. Differences between local GAAP and IFRS/US GAAP are generally “temporary”
in nature.
7
Chapter 1 - Introduction to Tax Accounting
Calculating the current tax expense is thus equivalent to preparing the cur-
rent year tax return. There is no guidance provided by IAS 12 for this pro-
cess. It basically comes down to applying (local) tax law to the current year
results. Examples of other items that impact the overall tax expense include
credits; offsetting losses; and different jurisdictions and their different rates.
There may be a need to correct the calculated current tax expense as deter-
mined in previous periods. These adjustments could occur due to improved
and/or additional knowledge gained in relation to the tax position taken in
the published financial statements. Although not often seen in practice, the
author would like to introduce a different use of the terms “return-to-accrual
adjustments” and “true-ups”.
8
How are income taxes accounted for?
The recognition of deferred tax is based on the principle that the tax effects
of transactions recognized in the financial statements should be recognized
in the same period as the transactions themselves, even if recognition in the
income tax return is in a subsequent period. In this situation, when transac-
tions are recognized for financial reporting purposes in different periods
than the tax return, temporary differences are generally created.
An entity analyses each of its assets and liabilities by comparing the carry-
ing value with its tax basis. The carrying amount is the amount for which
an asset or liability is recognized on the balance sheet.24 The tax basis is the
amount attributed to an asset or liability for tax purposes. Generally, this is
the value attributed to an asset or liability in the tax return in determining
whether cash flows resulting from the recovery/(settlement) of the entity’s
assets and liabilities will be taxable/(deductible).
23. US GAAP uses true-up adjustments for all adjustments up to filing the corporate
income tax return, and uses prior-year adjustments for adjustments after the moment of
filing the corporate income tax return.
24. There is a difference between IFRS and GAAP, in that the IFRS carrying amount
is equal to the amount recognized on the IFRS balance sheet, while the local GAAP car-
rying amount is equal to the amount recognized on the local GAAP balance sheet.
9
Chapter 1 - Introduction to Tax Accounting
In this fourth step, the temporary differences that were analysed in Step 1
are multiplied by the appropriate tax rate to calculate deferred assets and lia-
bilities. The tax effects of unused tax losses and unused tax credits are also
identified and considered.25 Generally speaking, the change in an entity’s
deferred tax position on the opening and closing balance sheet dates (gener-
ally resulting from the origination and reversal of temporary differences in
the current period) is the deferred tax expense/(income) for the period. For
exceptions to this rule, see chapter 5.
Deferred tax liabilities are recognized for all taxable temporary differences,
subject to limited exceptions discussed in chapter 9.26 Deferred tax assets,
however, are recognized in the financial statements to the extent that it is
probable that sufficient taxable profits will be available against which the
deductible temporary difference (or tax loss or credit) can be utilized.27 For
this reason, an entity with deferred tax assets must evaluate its sources of
future taxable profit as part of its income tax provision process in order to
determine whether they must be recognized.
25. IAS 12, para.13 (the benefit relating to a tax loss that can be carried back to recover
current tax of a previous period shall be recognized as an asset). IAS 12, para. 34 (a deferred
tax asset shall be recognized for the carry forward of unused tax losses and unused tax
credits to the extent that it is probable that future taxable profit will be available against
which the unused tax losses and unused tax credits can be utilized).
26. Ch. 9, para. 1, the initial recognition exemption.
27. IAS 12, paras. 34-36.
28. IAS 12, para. 36.
10
How are income taxes accounted for?
Tax law is complex, and positions taken in the tax return can often be inter-
preted in various ways, leading to disputes with the tax authorities and,
sometimes, an assessment of additional tax being due. Common examples
of uncertain tax positions include dividends and/or the application of par-
ticipation exemptions, transfer pricing principles, interest deduction restric-
tions and the applicability of tax rulings.29
While an entity may have a technical basis for the position taken in the
filed corporate tax return, these tax positions may still be “uncertain” if
there is more than one way to interpret the applicable tax law as applied to
the entity’s facts or if there is uncertainty whether a taxation authority will
accept an uncertain tax treatment. If so, an entity needs to consider whether
it is necessary to recognize a tax liability30 for the respective uncertain tax
position.
Here, the tax accounts recognized in the balance sheet position are adjusted
to reflect the current year’s tax provision calculated in the steps described
above. This step can be just as simple as it can be complex. The final posi-
tion on the balance sheet is the difference between the starting position, the
payments/revenues and the calculated current tax expense. Attention needs
to be paid to the fact that only income taxes may be taken into account, as
well as that there could be numerous other effects31 that impact the position
during the year.
The total tax expense is calculated as the sum of the total current tax expense
and the deferred tax expense. Deferred tax expense is equal to the difference
between deferred tax assets and liabilities.32 Logically, it follows that:
– as deferred tax assets increase, deferred tax expense decreases;
– as deferred tax liabilities increase, deferred tax expense increases;
– as deferred tax assets decrease, deferred tax expense increases; and
– as deferred tax liabilities decrease, deferred tax expense decreases.
11
Chapter 1 - Introduction to Tax Accounting
While the current and deferred tax expense from current year activities was
calculated in earlier steps, sometimes additional entries are required in order
to correct the
the tax
taxaccounts
accountsononthe
thebalance
balancesheet,
sheet,asasa result
a result
of of mispostings
incorrect post-
or other
ings minorminor
or other errors.
errors.
In this penultimate step, which is to determine the effective tax rate recog-
nized in the income statement, it is necessary to make a reconciliation from
profit before tax multiplied by the statutory tax rate. The effective tax rate
is the total tax expense divided by the profit before tax. If the tax rate can-
not be reconciled, the overall tax provision calculation is not complete. The
effective tax rate is used to “prove” the income tax expense of a company,
and it is a key performance indicator for listed companies. The effective tax
rate is used by analysts, investors and other stakeholders to measure the tax
function and its performance. Already for this reason, it is a required and
significant disclosure in the financial statements.
There are many different items that affect the effective tax rate, including:
– permanent differences;
– return-to-accrual and true-up adjustments;
– the change in an entity’s (un)recognized deferred tax assets;
– credits that directly reduce tax;33
– changes in tax liabilities recognized for uncertain tax positions;
– changes in applicable tax rates on the measurement of deferred assets
and liabilities; and
– jurisdictional rate differences.34
Once done correctly, the effective tax rate and the rate reconciliation are
useful calculations in determining whether all transactions have been
accounted for correctly.
12
Other factors affecting tax reporting: Looking beyond the accounting
requirements
Step 10: Prepare the financial statement reporting and disclosure notes
(chapter 8)
This is arguably the most crucial step. It leads to the determination of what
(additional) narrative and/or figurative information is required, as well as,
more significantly, the decision regarding what information is desirable for,
and of use to, (potential) investors. One question concerns what information
they wish to know and at what level of detail the company should provide
such information. This chapter deals predominantly with the requirements
as specified in IAS 12, paragraphs 79 through 88. It also presents some best
practices of disclosing taxes.
1.5.1. Introduction
This section will discuss other factors that currently affect and determine
the daily activities of a tax accountant, including the increased pressure on
corporations and their tax and finance departments, which do not have their
origin in the accounting and disclosure requirements under IFRS.35 Since
the beginning of this century, there have been other significant influences
that determine the debate on income tax reporting arising from jurisdictional
statutes, institutional investor pressure and media coverage. Especially the
latter is driven by public demands, based on the perception that multinational
13
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